The Centers for Medicare and Medicaid Services (CMS) held its last Home Health, Hospice, & DME Open Door Forum (ODF) for the year on December 11, 2013. The following information and updates pertaining to home health were provided by CMS staff.
Jimmo v. Sebelius Settlement Agreement
CMS has issue revised portions of the relevant chapters of the program manual used by Medicare contractors and providers, in order to clarify that coverage of skilled nursing and skilled therapy services “…does not turn on the presence or absence of a beneficiary’s potential for improvement, but rather on the beneficiary’s need for skilled care.” Skilled care may be necessary to improve a patient’s current condition, to maintain the patient’s current condition, or to prevent or slow further deterioration of the patient’s condition. Click here to view Change Request 8458
Provider Enrollment, Chain and Ownership System (PECOS) Edits
CMS officials reminded participants that the edits to ensue the referring/ordering physician listed on the Medicare home health claim is enrolled in Medicare will be activated on January 6, 2014. A revised Medicare Learning Network®MLN Matters® articlewas issued on November 6.
The edit will compare the first four letters and of the physician’s last name and the national provider identifier (NPI). Claims will be denied where the ordering/referring provider is missing, incomplete, or invalid, or that the ordering/referring provider is not eligible to order or refer. Claims submitted identifying an ordering/referring provider where the required matching NPI is missing will continue to be rejected. The edit will be applied to home health claims with a “From” date on or after January 6, 2014. Also, claims that are denied because they failed the ordering/referring edit will not expose a Medicare beneficiary to liability. Therefore, an Advance Beneficiary Notice is not appropriate in this situation.
CMS has made available the “Ordering Referring Report” on the Medicare provider/supplier enrollment website for providers to confirm whether a physician is Medicare enrolled. The file contains the NPIs and the names of physicians and non-physician practitioners who have current enrollment records in PECOS and are of a type/specialty that is eligible to order and refer. CMS confirmed for NAHC that the file will be updated two times a week, and not once a week as stated on the call.
Click here to view the MLN Matters article.
Home Health Consumer Assessment of Healthcare Providers and Systems (HHCAHPS)
Participants were reminded that the deadline for submitting HHCAHPS data for third quarter 2013 is January 16, 2014. Agencies should always confirm that their data has been submitted and received. The deadline for filing an HHCAHPS Participation Exemption Request (PER) Form for the Calendar Year 2015 Annual Payment Update (APU) is 11:59 PM Eastern Time on January 16, 2014.
Medicare-certified HHAs that served 59 or fewer unduplicated patients who met survey eligibility criteria between April 1, 2012 and March 31, 2013 should request an exemption from participating in the HHCAHPS Survey for the CY 2015 APU by completing the online PER form here.
HHPPS Rate Update
CMS issued a final rule to update Medicare's Home Health Prospective Payment System (HH PPS) payment rates and wage index for calendar year (CY) 2014. As required by the Affordable Care Act, this rule implements rebasing adjustments, with a 4-year phase-in, to the national, standardized 60-day episode payment rates; the national per-visit rates; and the NRS conversion factor. Payments to home health agencies (HHAs) are estimated to decrease by approximately 1.05 percent in CY 2014, reflecting the combined effects of the 2.3 percent HH payment update percentage the rebasing adjustments to the national, standardized 60-day episode payment rate, the national per-visit payment rates, and the NRS conversion factor), and the effects of ICD-9-CM HH PPS Grouper refinements.
This final rule also discusses the transition to ICD-10-CM coding, establishes home health quality reporting requirements for CY 2014 payment and subsequent years, specifies that Medicaid responsibilities for home health surveys be explicitly recognized in the State Medicaid Plan, and revises the methodology for calculating state Medicaid programs’ fair share of Home Health Agency (HHA) survey costs. Click hereto view the final rule and additional relevant documents. Also,a draft list of Manifestation and Etiology codes is provided in the Downloads section. The list is being provided for review and comments or questions regarding the list of manifestation and etiology codes will be accepted through December 30, 2013 via e-mail to firstname.lastname@example.org.
CMS officials reminded participants of the requirement to include service location Q codes on claims. Effective for HH episodes beginning on or after July 1, 2013, HHAs are to use the HCPCS codes Q5001 (Hospice or home health care provided in patient’s home/residence), Q5002 (Hospice or home health care provided in assisted living facility) or Q5009 (Hospice or home health care provided in place not otherwise specified (NO)) on home health claims to report where home health services were provided. The Medicare contractors have reported a higher number of claims that are being returned to the providers for error code 31790 which indicates a Q code is not listed on the claim.